‘may contain’ labelling – the consumer’s perspective

‘May Contain’ Labelling – The Consumer’s Perspective

Be Allergy Aware

Further copies may be obtained from:

Food Standards Agency Publicationson tel: 0845 606 0667 or email: [email protected]

Administrative Information

Research undertaken: October to December 2001

Project commissioned by:

The Food Standards Agency

Aviation House

125 Kingsway

London WC2B 6NH

Project Officer: Dionne Davey

Chemical Safety and Toxicology Division

www.food.gov.uk

Contractor:

The Anaphylaxis Campaign

PO Box 275

Farnborough

GU14 6SX

Tel: 01252 542029

www.anaphylaxis.org.uk

Sub-contractor:

Hazel Gowland

Allergy Action

23 Charmouth Road

St Albans

AL1 4RS

Tel: 01727 855294

[email protected]


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SummaryConsumers who are allergic to nuts and peanuts need to avoid them asingredients. They also need to avoid other foods which may carry a riskof trace contamination because they have not been segregated fromthese allergens during manufacture. Anecdotal indications suggest thatsuch consumers take longer to shop, find it difficult to locate, read andbelieve nut trace contamination information, may have to pay more fortheir food and have a restricted choice. This shopping basket comparisonwas carried out to find out whether such anecdotal indications weresupported by evidence from buying and examining pre-packed foodproducts in supermarkets.

The study aimed to:Focus on nut trace contamination (NTC) labellingNuts and peanuts are recognised as the most likely food allergens totrigger serious allergic symptoms. UK manufacturers and retailers whoknow this may indicate their presence on the packet.

Determine the prevalence of such labellingIn a basket of everyday food items (selected because they do notnormally contain nuts as ingredients), 56% indicated a risk of nut tracecontamination (71/127 items). The study indicated that nut allergic*consumers are unable to buy a match or substitute for 18% of the itemslisted. In addition, in many cases, they are forced to accept a substituteor poorer quality product (9%). They take 39% longer to shop and pay 11%more on average.

Examine the variety and style of such labellingOn products examined, ingredient information was allocated an averageof 2.6% of the packaging area. Additional allergen information covered anaverage of 0.53%. Long-established industry guidelines to make labellingclear are often ignored. 37% of all products examined (95/254) had keyinformation in poor colour combinations. There is little consistency inlabelling style between different retailers or manufacturers. These andother factors make it very difficult for allergic consumers to find and readessential information.

Report on current practiceBiscuits, cereals and confectionery are most commonly cited by nutallergic consumers as those products that are hard to find without nuttrace contamination information. Packaging examined often displayednut trace contamination information which was not always noticed bythe shoppers or sorters. Similar allergen warnings on a variety ofproducts may reflect very different degrees of risk to the allergicconsumer.


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*For the purposes of this report any reference to nut allergic includes peanut (groundnut) as wellas the tree nuts (hazelnuts, brazil, walnuts etc)

There is confusion among consumers over the status of sesame andcoconut as nuts for labelling purposes.

Comment on the allergen risk assessment, management, andcommunication of different manufacturers and retailersSome manufacturers and retailers are identifying the risk of nut tracecontamination for the first time, and beginning to use warning labels.Others have recognised the problems for allergic consumers and are keento find ‘nut free’ suppliers and remove NTC labels.

Make recommendations Key recommendations include improved labelling of all ingredients onall foods, clearer allergen information, and support for manufacturerswho are determined to remove nuts from their production. In addition itis important to undertake regular reviews of the quality and legibility ofall essential information on pre-packed foods. It is important that thiswork is linked into parallel Food Standards Agency activities.


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ADMINISTRATIVE INFORMATION i

SUMMARY ii

CONTENTS v

INTRODUCTION 1

Background 1

A: PARALLEL SHOPPING BASKETS 5

A:1 Buying the food products 5

Methodology 5

The shopping trips 5

Instructions to shoppers 6

Choosing the items for the Shopping List 6

The shopping list 8

A:2 Recording the food products 9

Conclusion 12

Consumer choices 12

Time 12

Cost 12

B: LABELLING ASSESSMENT 13

B:1 Measuring the packaging area and the percentage used for ingredient and allergen information 13

Methodology 13

B:2 Devising an assessment scheme and recording the labelling attributes for all items 15

Methodology 15

The assessment scheme 15

Contents

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Conclusion 19

C: LABELLING AUDIT 20

Methodology 20

Results 21

Labelling examples 21

Basket sorting: individual details 41

Quotes from the basket sorters 42

Additional sample labels 42

Particular issues with brand label items 44

D: REVIEW OF RECENT ANAPHYLAXIS CAMPAIGN NTC LABELLING ENQUIRIES 50

Health food stores 50

Small suppliers 50

Farmers’ Markets 50

Biscuits, cereals and confectionery 51

Cereals 51

Biscuits 52

Confectionery 52

Sesame trace contamination 52

E: REVIEW OF CURRENT ALLERGEN LABELLING ON PRE-PACKED FOODS 53

CONCLUSION 56

RECOMMENDATIONS 57

Annex 1 References 58

Annex 2 Nut Trace Contamination Labelling Examples 59

Annex 3 Glossary of definitions 60

Annex 4 Acknowledgements 61


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Introduction

Background

The Anaphylaxis Campaign is a UK-wide registered charity set up tosupport those at risk from potentially fatal food allergies. It now has nearly7000 members. Since its foundation in 1994, there has been an enormousincrease in awareness of such allergies, and significant Campaign initiativeshave been undertaken to improve food information and to support thoseat risk. These have included work with Ministry of Agriculture, Fisheries andFood (MAFF), the Department of Health, and now with the Food StandardsAgency. Additional independent projects with individual foodmanufacturers, retailers and catering businesses, work with professionalbodies to draw up industry codes of practice and guidelines, on-sitetraining and risk assessment, and other initiatives have also aimed to assess,manage and communicate allergen risks and improve the food choices forallergic people.

Food allergic consumers who have consumed or even had contact withthe tiniest trace of an allergen to which they have been sensitised mayexperience unpredictable symptoms which could lead to life-threateningasthma or anaphylaxis. In the absence of any appropriate preventativetherapy, those who are aware that they are at risk are required to carryout vigilant allergen avoidance. There are over 170 recorded triggerallergens but the most common include peanuts, tree nuts, sesame, cows’milk, eggs, fish, shellfish, wheat and soya. Over 90% of the AnaphylaxisCampaign’s members have an allergy to peanuts and/or tree nuts.

It is likely that one child in 100 may suffer allergic symptoms to peanutswhich could become potentially life-threatening(1). In most cases theallergy will last into adulthood, and the person would be advised toavoid all contact with tree nuts (hazelnuts, brazils, walnuts etc). Mostfamilies with a nut allergic child will avoid nuts and peanuts, both asingredients and as trace contaminants. Other people with whom theyshare food will also be encouraged to avoid them. This may well include

It has been calculated that the prevalence of adverse reactions tofood and food ingredients is 1.4 – 1.8%. Most adverse reactions tofoodstuffs are to natural foods rather than to synthetic additivesand contaminants, the prevalence of which is about 0.3%. Theprevalence of allergy to food and ingredients is estimated to beup to 8% in infants and young children. Anecdotal evidencesuggests that the largest number of people at risk of severeallergic reactions react to peanuts and tree nuts; therefore thiswork is focused primarily on nut and peanut trace contamination.

The Food Standards Agency

school meals, packed lunches, eating out, group outings and holidays,sport and leisure activities. In practice, this means that thousands ofpeople caring for children are trying to buy everyday foods that aresuitable for nut allergic people. The Anaphylaxis Campaign has heard offamilies which do not have a nut or peanut allergic child, but in which allcontact with nuts and peanuts is avoided ‘just in case’. In addition, manyfamilies have to avoid other allergens which trigger symptoms in theirchildren such as egg, cows’ milk, soya and sesame. Finding foods withoutallergens to which their child is allergic is frequently described as anightmare.

The Government has long recognised many of the issues relating to tracecontamination by allergens. In the past both MAFF and the Departmentof Health, and now the Food Standards Agency have worked closely withthe Anaphylaxis Campaign. All are increasingly aware of many of theissues facing allergic consumers.

In recent years, food manufacturers and retailers have responded to thewider identification of this risk and its increased prevalence by assessing,managing and communicating it on a wide range of pre-packed and otherproducts. This has led to the use of allergen labelling eg “May containtraces of nuts.” In the early days, such labelling was consideredresponsible and helpful to allergic consumers, but as the range andnumber of products labelled in this way increased, consumers began toquestion whether the food suppliers were using it defensively “to covertheir backs.” The use of NTC information on apparently unrelatedproducts such as pre-packed salads, boiled sweets, tomato sauces andmany other items, has led to the devaluation of its message. If themajority of an ordinary product range on supermarket shelves (egbiscuits, cereals, confectionery) carries such warnings, it is easy tounderstand why people disbelieve them.

The Anaphylaxis Campaign recognises the particular risks for allergicteenagers and young adults and supports them through specialistworkshops. These offer the opportunity to discuss their consumerbehaviour and allergen avoidance strategies. Many openly declare thatthey disregard allergen trace contamination information on products.They cannot believe that such a huge proportion of food products onsale may put their lives at risk, and many are cynical about the reasonsbehind their use. In addition, they point out that if a risk were serious, itwould have to take up more space on the packet and be much easier tofind and read.

The legibility of allergen warnings has been compared with that ofcigarette health warnings which, by law, have to take up a significantproportion of the pack surface. The UK is about to introduce newrequirements for health warnings on tobacco products. A new EULabelling Directive (Directive 2001/37/EC) lays down new specificationsfor the size, layout, positioning and text of health warnings. This willcome into effect on September 30th 2002. Under the new Directive all


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cigarette packets will have to carry a warning saying either 'Smoking kills'or 'Smoking seriously harms you and others around you'. This must cover30% of the front panel. On the back of the pack there will be anadditional warning which can be selected from a list of 14 options. Thiswarning must cover 40% of the back panel. The purpose of thesewarnings is to prevent ill-health and, in the longer term, death unlikeallergen information which may prevent death within minutes. Thousandsof people need accurate and clear information about food ingredientsevery day, to prevent symptoms which are often unpleasant, and in somecases very dangerous, and yet the information available to them is oftenhard to find and hard to read.

The Food Standards Agency and the Anaphylaxis Campaign have bothreceived complaints and reports of the perceived increase in the use andquality of allergen labelling, particularly with reference to nuts andpeanuts. Consumers wonder whether manufacturers and retailers areusing them before undertaking a careful risk assessment.

The Anaphylaxis Campaign is now considered a UK-wide authority onmanaging allergen risk and receives a constant flow of enquiries fromallergic consumers, and food professionals representing all points of anincreasingly complex food supply chain.

This initiative was devised to give an immediate overview of the currentuse of NTC information on pre-packed foods. Its main purpose was toexamine the choice of foods and information available to the nut allergicconsumer.

The Food Standards Agency’s brief was to:

• Focus on nut trace contamination labelling

• Determine the prevalence of such labelling

• Examine the variety and style of such labelling

• Report on current practice

• Comment on the allergen risk assessment, management, andcommunication of different manufacturers and retailers

• Make recommendations


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Initial research was carried out through the followingactivities:

• Activity A: Parallel Shopping Baskets

• Activity B: Labelling Assessment

• Activity C: Labelling Audit

The report includes the following sections:

• D: Review of recent Anaphylaxis Campaign NTC labelling enquiries

• E: Review of current allergen labelling practice on pre-packed foods

Conclusions

Recommendations


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Activity A: Parallel shopping baskets

A:1 Buying the food products

Methodology

Shoppers were commissioned to visit 8 retailers to purchase a definedlist of items. Shoppers made two consecutive trips per store, the first topurchase goods for a non-nut allergic consumer (control). On the secondshopping trip, the shoppers were asked to buy the same items for a nutallergic person, only making an alternative choice if they considered theoriginal items unsuitable for a nut allergic consumer.

The shoppers were asked to buy 16 pre-packed own brand items from aset list. The items were selected on the basis of being everyday items foran average consumer, none of which usually contain nuts or peanuts asingredients. Shoppers were given suggested acceptable alternatives andasked only to buy a branded item when an own brand item was notavailable. The time, cost and selection of items were recorded for eachof the visits to the store. The shoppers were encouraged to use allinformation resources available in the store including labelling, shelf edgenotices, signage and asking staff if necessary.

The retailers visited in this survey were ASDA, the Co-op, Iceland, Marksand Spencer, Safeway, Sainsbury’s, Tesco and Waitrose. All the branchesvisited were in mid-Hertfordshire. Some were on major out of town sites,whilst others were in the town centre, or on local estates.

At the end of the research period, an additional brand label shopping tripwas undertaken. This enabled a labelling comparison between brandleaders and own brand items produced for individual retailers. Somewere chosen according to the Grocer Magazine Annual Review (Class of2001)(2).

The Shopping Trips

The shopping trips took place during the day on a weekday when storeswere more likely to be properly stocked but not too busy. The shopperswere chosen because they do not usually shop for an allergic person, and

Objective:

The purpose of this activity was to compare the availableconsumer choice, time and cost of a shopping basket of everydayitems for a nut allergic consumer with one for a non-nut allergicconsumer.


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were unfamiliar with the store. For practical convenience, it was decidedthat the same shopper should make both the first and second trips toone store. This had the disadvantage that they were more familiar withthe store during the second trip and they may have taken less time. Theadvantage to this was that their shopping choices in the control and‘suitable for a nut allergic person’ baskets were more consistent. Thisenabled a closer comparison of consumer choices (control and nutallergic) for later activities. The time taken to select the items wasrecorded. This did not include time spent at check-out, queuing or payingfor the goods.

Instructions to shoppers:

Choosing the items for the Shopping List

The items on the list were chosen for the following reasons:

• They do not conventionally contain nuts or peanuts

• They are everyday items

• Many are regularly eaten by children

• They are commonly consumed and widely available – even in localor smaller stores. (In fact only one of the control baskets from thefirst shopping trips had an item missing. This was a sandwich.)

• Anaphylaxis Campaign members frequently complain of difficulty infinding these items without NTC labelling

• There is also the perception that many of these items have NTCwarning labelling which is used inconsistently

Shopping Survey

1. Please select the following articles in the store

2. Please buy the store’s own brand when you can

3. Please use any information available, on the shelf, on the label,from signs or from staff in the store

4. The time taken to select the goods is important

5. If the first choice is not available, please select the secondchoice. If that is not available, use your discretion and buy whatyou would choose for a friend.


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• They include chilled, frozen and canned items, and are sold in a widerange of packaging materials

• Some of them reflect the trend towards ready meals andconvenience foods

Many allergic consumers report difficulty finding bread and other bakeryproducts without a nut contamination risk. The Anaphylaxis Campaignand many retailers have recognised that the risk of cross-contaminationin in-store and local bakeries is quite high, and nut and sesame allergicconsumers are advised to avoid them. This restricts their choice tofactory-packed bakery items. These do not usually carry NTC informationand have not been included in this work. Pre-packed currant buns wereincluded as representative factory-baked items.


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The Shopping List:

Please buy the store’s own brand

1. Tin Chicken Curry (plainest available) c400g

2. Smallest available pack of rice crisp cereal (2nd choicecornflakes)

3. Smallest available pack of Bran flakes

4. Packet of cream crackers

5. Bar of milk chocolate c200g

6. Box of 6 apple pies (2nd choice other fruit pies)

7. Small pot of coleslaw – plain version

8. Bag of fruit jelly sweets (2nd choice fruit pastilles or similar)

9. Smallest available pack of bourbon (chocolate sandwich)biscuits

10. Jar of pasta sauce (plainest tomato version)

11. Fresh cheese and tomato quiche (6-7 inch) (2nd choiceQuiche Lorraine or vegetable)

12. Frozen Chinese meal for one (sweet and sour chicken orpork) (2nd choice chop suey)

13. Fresh plainest egg sandwich (2nd choice fresh plainest cheesesandwich)

14. Pre-packed packet of currant buns (2nd choice fruit teacakes)

15. Box of frozen milk choc ices (2nd choice plain or white choc)

16. Smallest available pack of chocolate covered wrappedbiscuits eg sandwich or wafer (Store’s own ‘penguins’ or similar)


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A:2 Recording the food products

Once the items were purchased, they were coded, labelled and stored.Packaging was removed from perishable items. All purchases wererecorded on a master log. Each item was decided to be a match asdescribed on the shopping list or a substitute. Items which were notavailable were recorded as no shows. There was 1/128 items missing fromthe control basket selection, and 23/128 missing from the nut allergicconsumer’s basket. This was because the shoppers were unable to find amatch or a substitute. Prices were recorded from receipts, and weights /quantities noted.

The items most frequently substituted included bourbons which werereplaced by chocolate digestives, cereals (by other cereal types), curriesand Chinese meals with different meats from those specified, or in somecases no meat content at all, and other types of quiche. This is exactlywhat happens when allergic consumers shop. In many cases, the switchto a substitute (without NTC labelling) takes place automatically; theshopper is reluctantly resigned to the restricted choices available.

The items most frequently recorded as ‘no shows’ were the egg sandwich,the coleslaw and the tin of curry. In Marks and Spencer where all itemsare ‘own brand’, there were three substitutes and six items missing fromthe basket for the nut allergic person. In other stores, the shoppers hadto buy branded items. In the smallest store (Co-op) there were twosubstitutes and six items missing. It is likely that restricted shelf space inlocal stores limits the available mix of branded and own brand items.

TABLE 1: CONSUMER CHOICESDifferences between control and nut allergic consumer’s shop

Control basket Nut allergic consumer’s basket

Matches 119 93

Substitutes 8 12

No shows 1 23

Total items bought 127/128 105/128

(Set list of 16 items/8 shops)


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TABLE 2: TIMEDifferences between control shop and nut allergic consumer’s shop

Control basket Nut allergic consumer’s basket

Total time 145 minutes 167 minutes

Total number of items purchased 127 105

For 16 items

Maximum visit time 25 minutes 40 minutes

Minimum visit time 11 minutes 18 minutes

Average time per visit 18 minutes 25 minutes


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The shoppers reported that they obtained allergen information onallergen information from the packaging. However on occasions they didhave to check with in-store staff whether bakery items in particular werepre-packed (ie made in a factory) or made in store.

TABLE 3: COSTDifferences between control shop and nut allergic consumer’s shop

Control Shop Nut AllergicConsumer’s Shop

ITEM AVERAGE PRICE £ AVERAGE PRICE £

1. Tin Curry 1.57 1.46

2. Rice cereal 1.15 1.24

3. Bran Flakes 1.23 1.47

4. Cream Crackers 0.40 0.46

5. Milk Chocolate 0.75 0.74

6. Apple pies 0.85 0.67

7. Coleslaw 0.52 0.65

8. Fruit jelly sweets 0.75 0.87

9. Bourbon biscuits 0.53 0.64

10. Pasta sauce 0.92 1.15

11. Quiche 1.87 2.00

12. Chinese meal 2.00 1.63

13. Sandwich 1.19 1.48

14. Currant buns 0.69 0.82

15. Choc ices 0.99 1.95

16. Chocolate biscuits 0.74 0.73

Total price £16.15 £17.96


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Conclusion

Consumer Choices

When shopping for a nut allergic consumer, the choice of everyday itemswas restricted. Only 73% (93/128) of items were available to a nut allergicperson, compared with 93% (119/128) for the control consumers. Inaddition, the nut allergic consumer missed out on 18% (23/128) of itemsfrom the list when a match or substitute were not available. It is worthremembering that the items listed do not usually contain nuts asingredients and that many are often consumed by families with children.

Time

The shoppers made two consecutive visits to each store. The shoppermay have become more familiar with the store layout during the secondvisit which would reduce shopping time. However, the amount of timetaken to buy items for the nut allergic consumer was greater. Allowing anaverage of the time taken to buy each item, the control shop took18 minutes, whilst the nut allergic consumer’s shop took over 25 minutes(39% longer).

Cost

The average cost of the control basket was £16.15, whilst the basket forthe nut allergic consumer cost £17.96 (11% more). It is worth noting thatitems were sometimes cheaper in the nut allergic consumer’s basket. Thiswas because the shoppers chose items such as apple pies or currant bunsfrom economy lines which carried no NTC labelling. This may have beenbecause a factory risk assessment had indicated no need to use NTClabelling. Sometimes economy lines are less likely to have come intocontact with relatively expensive ingredients such as nuts. In these cases,the cost to the allergic consumer is not in money but in choice andquality.


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Activity B: Labelling Assessment

B:1 Measuring the packaging area and the percentageused for ingredient and allergen information

Methodology

This activity involved a detailed analysis of each item purchased in thesurvey (254 items including the additional brand label products). Theproportion of the packaging area available for labelling and used todeclare ingredients were measured and recorded. Any additional areadedicated to allergen declarations (both as ingredients and as NTCinformation) was also measured and calculated as a percentage of thetotal package area. Advice for consumers with food intolerances andcoeliac disease was counted as allergen information.

The space dedicated to ingredients is a critical starting point for allconsumer allergen risk assessment decisions. Ingredients information isallocated on average 2.6% of the packaging area, and additional allergeninformation 0.53%. On a smaller packet, this is hard to read, and on alarger packet, it is hard to find. In a number of cases, the area dedicatedto both ingredients and/or allergens listing was very small. On largerpackets in particular, it often represented a relatively small fraction of

TABLE 4: Table to show the proportion of the packaging dedicated

to ingredient and allergen (including NTC labelling)as a percentage of the total surface area available

Packaging areaavailable for Average Maximum Minimum

% % %

Ingredients (254) 2.60 12.50 0.25

Allergens (140) 0.53 4.08 0.02

Objectives

The objective was to assess how much of the packaging area wasused for total ingredients and for allergen information. Thelabelling was also assessed against recognised criteria forassessing legibility and providing consumer information.


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the available surface (eg 0.04% on a packet of bran flakes). It is often verydifficult to find the ingredients on a larger packet, and manufacturers andretailers rarely make good use of the space available to make ingredientsor allergen information more easy to find or legible. It is not thereforesurprising that people take 39% longer to shop for nut allergic consumers.

Although some products did not have NTC or allergen labelling,information about individual ingredients was hard to find and difficult toread. It must be remembered that shoppers who are trying to find outwhether a product is ‘safe’ for an allergic consumer still have to workthrough all the ingredients on all products.


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B:2 Devising an assessment schemeand recording the labelling attributesfor all items

Methodology

The next activity was to make an objective assessment of the attributesof labelling on all 254 items.

The Assessment Scheme

The assessment scheme was devised using a number of key sourcesincluding the Institute of Food Science and Technology GoodManufacturing Practice (GMP) guidelines for food manufacturers dealingwith allergens(3), guidance from the Royal National Institute for the Blindto support customers with sight problems(4), Voluntary LabellingGuidelines from the Institute of Grocery Distribution(5), papers by Dr SueHefle and Dr Steve Taylor in the Leatherhead Food Allergy andIntolerance Journal(6) and the Food Standards Agency’s Clear LabellingTask Force recommendations(7).

“The presence or potential presence of a major serious allergenshould be separately stated, in a prominent and easily legible way,where it will clearly be seen by a potential purchaser undernormal conditions of display.”

Institute of Food Science and TechnologyGood Manufacturing Practice 1998

“Food-allergic consumers should and do use the information onthe package label as their primary source of information…”

“First and foremost, the ingredients statement should ideallycontain all information that would be beneficial to allergicconsumers.”

Dr Steve Taylor and Dr Sue Hefle 2001


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The Institute of Grocery Distribution recommendscommunication:

“To emphasise the need for a thorough HACCP-based evaluationof the possible unintentional presence of traces of peanuts ortree nuts, and the need for operating a system of GMP tominimise, and ideally to eliminate, the unintentional presence ofthese foods.”

And offers the following recommendation:

Advisory (allergen) labelling should, wherever possible, appear asa separate line immediately below the list of ingredients and inthe same field of vision. It should be at least the same print sizeas that used for ingredients.

Voluntary Labelling Guidelines 2000

Food Standards Agency Clear Labelling Task ForceRecommendations on Ideal Label Formats 2002(Guidelines for the industry)

“Do not hide, obscure or interrupt product information with anyother written or pictorial matter. Make sure that all productinformation is easily visible and clearly legible.”

“Ideally use a font size of 10 point for the essential information.”(eg ingredients)

“Metallic and shiny surfaces make reading difficult. Try to use amatt-finish printing surface.”

“Simple icons can help direct consumers to information.”(“signposting”.)

“Avoid ‘reversing-out’. In any event, only use it for white type on ablack background.”

“Only use italics for isolated words – Do not use them for largeblocks of text, or for small font sizes.”

“Adopt a consistent format when presenting information on arange of products to make it easier for consumers to identify andlocate.”

“Do not use all upper-case letters or underlining for emphasis.”


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The RNIB also point out that there are 1.7 million blind and partially-sighted people in the UK. It is likely that some of them are consumerswho need allergen and other ingredients information.

The RNIB guidelines include the following recommendations:

• “The size of the type significantly affects its legibility

• A minimum of 12 point should be used

• The choice of typeface is less important than size and contrast

• Avoid italic typefaces

• People with sight problems often prefer bold (type weights)

• The spacing between one line and the next (known as leading)is important

• The contrast between the background and the type is alsoextremely important. Contrast will be affected by the size andweight of the type

• Avoid glossy paper because glare makes it difficult to read

• When folding paper, avoid creases which obscure the text.”


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TABLE 5:Labelling attributes by percentage

PRODUCTS IN CONTROL BASKET Number %(127/254) 127

Product in control basket has NTC information 71 56

Use of symbol for NTC 6 5

PRODUCTS WITH ALLERGEN INFORMATION Number (140/254) 140

Allergen Information in same line of vision as 124 89ingredients

Allergen Information in allergen box 65 46

Allergen information in 12 point font or more 7 5

Allergens in Bold in ingredients list 3 2

Use of consistent style for allergens eg Warning or 77 55exclamation mark

Allergen information upper case 77 55

ALL PRODUCTS Number (254) 254

Ingredients in mixed upper and lower case 201 79

Ingredients in 12 point font or more 6 2

Use of black / dark on white / pale 149 59

Ingredients upper case 53 21

Paper shiny / creasable 103 41

Ingredients or NTC information under flap 9 4

Light blue on white text 18 7

Other hard to read colour combination 77 30

Typeface italic 31 12

Reversed text eg white on colour 48 19

Multilingual 25 10


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• More than half of the products purchased carried some kind ofallergen information or advice (140/254).

• Over half (56%) of the control basket items had NTC labelling(71/127).

• 5% had a special symbol to indicate the NTC information.

• 11% of the products carrying allergen information displayed it in aseparate field of vision from the ingredients list. This makes it verydifficult to find and contravenes the industry guidelines above.

• Only 2% of allergens were picked out in bold text in the ingredientslist.

Information was often presented in upper-case fonts, which isparticularly hard to read when used in a continuous multilingual line in atiny font on such items as ice creams and confectionery, particularly indark brown on a mid-brown background. Although the majority ofproducts used dark on white/pale, mixed upper and lower case letteringfor ingredients and allergen information in the same field of vision asingredients, ingredients font sizes were often tiny and hard to read. Overa third of products (95/254) had ingredients information in poor colourcombinations. 41% of products were presented in packaging which wasshiny or creasable. This can be very hard to read in normal supermarketlighting.

Conclusion

Whilst the own brand products demonstrated some consistency ofingredient and allergen information within each supermarket chain, theinformation was often hard to find and harder to read. Although the FoodStandards Agency Clear Labelling Task Force recommendations were notpublished in time to have had an impact on the items examined, otherlong-standing sources of guidance have clearly been ignored. TheInstitute of Food Science and Technology principle that the presence orpotential presence of an allergen should be stated “in a prominent andeasily legible way” is not always implemented in practice. It is alsoapparent that implementing the Task Force recommendations, will makean enormous difference in supporting the informed food choices of allthose who need to avoid allergens and other ingredients for healthreasons and personal choice.


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Activity C: Labelling Audit

Methodology

The control basket from each retailer was included in this assessment.The labels for all 127 items were carefully examined and a note made ofwhether they carried NTC information eg “May contain nut traces” or“Produced in a factory where nuts are used.” Other allergens such assesame, and coconut (which rarely trigger allergic symptoms in nutallergic people) were not counted as nuts. The products were recordedaccordingly.

Ten sorters carried out this exercise. They were not the same people asthe shoppers. 1/10 was used to shopping for a nut allergic person and1/10 was used to looking for information about cows’ milk.

All eight control selections were used for this activity. The sorters wereasked to divide the goods from each retailer’s basket in turn into twoboxes, which were labelled as “Not suitable for a nut allergic person” or“Suitable for a nut allergic person”. The time taken was recorded, as werethe different choices of each sorter.

The sorters’ choices were matched against the actual pre-assessed NTCstatus. This enabled a precise assessment of whether they had noticedNTC information on each product.

Objective

The purpose of this activity was to find out how easy it is forconsumers to identify products for a nut allergic person. Acontrol basket from each retailer was examined by anindependent consumer after selection.


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Results

A number of sorters placed a suitable item into the box labelled “Notsuitable for a nut allergic person”. It is possible that they considered theproduct likely to have some NTC risk, even if it was undeclared. They mayhave misread an ingredient or counted sesame or coconut as a nut. (Ifthey asked, they were advised not to count them as nuts.)

This decision would reduce the choice to nut allergic consumers, butwould not put them at risk. On the other hand, sorters also missed NTClabelling and put unsuitable items in the suitable box. Such decisionswould put nut allergic consumers at risk.

Labelling examples

Samples of NTC labels for each retailer most frequently missed bysorters in Activity C are included on the following pages. It must beremembered that the sorters had to examine the whole item and find theingredients and allergen information. All of the sorters made some errors,and all retailers had products on which NTC labelling was missed. Theproducts most likely to have NTC labelling which were missed includedthe packets of wrapped chocolate biscuits, the own brand bran cerealsand the chocolate bars. Additional examples of branded labelling havealso been included for comparison.


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Basket Sorting: Error Analysis Notes66 selections put an 'A' item (NTC labelled) into the 'B' box (Suitable for a personwith a nut allergy)59 selections put a 'B' item (not NTC labelled) into the 'A' box (Not suitable for aperson with a nut allergy)10 people sorting items from 8 baskets (control selections from each of 8 retailers)containing 16 items (except there were only 15 items in the Iceland selection) =127 x 10 = 1270 selections.

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Sainsbury’s Bran Flakes: Three out of tensorters missed the NTC information.


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Sainsbury’s milk chocolate: Two out of tensorters missed the NTC information.


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Marks and Spencer Mince Pies: Two out often sorters missed the NTC information.


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Marks and Spencer Choc Ices: One out of tensorters missed the NTC information.


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Wilson’s Lamb Korma Curry: Two out of tensorters missed this (Contains nuts as ingredients)

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Waitrose Chocolate Biscuits: Twoout of ten sorters missed the NTCinformation.


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Waitrose Fruit Jellies: Sorters were unsurewhether coconut traces counted as nuts.

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Iceland Wholewheat Bisk Cereal: Two out often sorters missed the NTC information.


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Iceland Apple Pies: One out of ten sortersmissed the NTC information.


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Safeway Cream Crackers: Three out of tensorters missed the NTC information.


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Safeway Chinese meal: One out of tensorters missed the NTC information.


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ASDA Chinese Meal: Two out of ten sortersmissed the NTC information.


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ASDA Bourbon Creams: One out of tensorters missed the NTC information.


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Tesco Chinese meal for one: Three out of tensorters missed the NTC information.


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Tesco Milk Chocolate: One out of ten sortersmissed the NTC information.


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Co-op Bran Flakes: Two out of ten sortersmissed the NTC information.

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Co-op ChocolateBiscuits: All thesorters found thisNTC labelling.


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This prepared meal from Budgen has NTC information.(Budgen was not one of the supermarkets visited in Activity A.)

This provides an example of NTC labelling.


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Bourbon biscuits from Budgen.

Basket Sorting: Individual Details

Three out of ten sorters missed the NTC information on the Sainsbury’sBran Flakes. The allergen box under the ingredients is clear and conformsto industry guidelines. However, whilst some consumers will take morenotice of NTC information if it describes the risk (ie “Due to methodsused in the manufacture of this product, it is not suitable for nut allergysufferers”), the font is so small that it may be missed. Similar labelling onthe Sainsbury’s milk chocolate was also missed by two out of ten sorters.

The Marks and Spencer Mince Pies display the latest square version ofthe blue on white logo to indicate NTC risk of nut ingredients. Two outof ten sorters missed this altogether. Those who shop for nut allergicconsumers have to learn the different styles of each retailer they visit,before they can take full advantage of all the information provided. Theprevious oval Marks and Spencer NTC/nut ingredient logo is displayedon the Choc Ices. One person out of ten missed this warning.

The Wilson’s Indian Style Lamb Korma (Waitrose) actually has walnuts asan ingredient which were missed by two out of ten sorters. It was abranded product selected by our shopper in the first basket. Two sortersout of ten missed the NTC labelling on the Waitrose Chocolate coveredbiscuits. Reversing the text and placing the NTC information under theNutrition box away from the ingredients and on shiny paper does nothelp the consumer. Another Waitrose product which caused confusionamongst the sorters was the bag of jelly sweets which had a warningabout coconut trace contamination. Four people out of ten countedcoconut as ‘not suitable for a nut allergic person’. It is actually a palm andnot a tree nut. A tiny minority of allergic people may experiencesymptoms to coconut, but the majority of nut allergic consumers can eatit. The problem arises because it contains the word ‘nut’.

The Iceland red box allergen warning on their Wholewheat Bisk cerealwas missed by two out of ten sorters. The new style labelling on IcelandApple Pies was commended by three sorters as the clearest NTCinformation on any item. However, one sorter missed it altogether.

The NTC information on Safeway Cream Crackers was missed by threeout of ten sorters. It covers 0.70% (0.31cm2) of the label. The Sweet andSour Chicken warning was missed by one person. The NTC information isin another column from the ingredients in a small font and under theheading “Dietary Information”.

The NTC information on the ASDA Chicken with Rice was missed by twoout of ten sorters. The Bourbon Creams NTC label was missed by onesorter. The paper is very shiny and the NTC text is in italics.


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The Tesco Chinese meal for one NTC label was found by one shopper inthe store who chose it as an alternative for Basket Two. However, threeout of ten of the sorters missed this warning which is tiny and takesabout 0.32% (4.25cm2) of the surface of the box. The Tesco chocolate barNTC labelling was missed by one person out of ten. It is in reversed text,two columns away from the ingredients information on a very darkbackground.

Two out of ten sorters missed the NTC information on the Co-op BranFlakes. All the sorters found the NTC information on the Co-opchocolate covered biscuits even though it was printed on very shinypackaging.

Quotes from the basket sorters

Whilst the sorters were making their selections, some of their commentswere noted:

• “I don’t believe it. You can’t buy anything without these warnings.”

• “I’m shocked at how little is appropriate (for allergic people).”

• “If an item is properly labelled and I can read it, then I trust it (thewarning) more.”

• “You have to trust that the manufacturers understand all the issues.”

Additional sample labels

Samples were taken from all the shopping baskets including the brandlabel shopping selection.

A number of shoppers chose Walls Magnum Classic ice creams in BasketTwo because they appeared to be ‘nut free’. We were unable to find anynut trace contamination information on them. The ingredients are listedin many languages, in capitals and in dark text which is continuous, on adark background and hard to find and read. Consumers searching forinformation which may be life-saving find such products very frustrating.


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This Magnum Classic has no NTC labelling,but the ingredients are hard to read.

Particular issues with brand label items

Some manufacturers proudly claim that they do not make own branditems for retailers. This means that these manufacturers are not subjectedto unexpected audits, checks and HACCP (Hazard Analysis CriticalControl Points) protocols imposed by retailers. Some supermarkets havevery effective procedures for assessing, managing and communicatingallergen risks, and have endorsed segregated production, staff trainingand a wide range of other measures to protect products from allergencontamination.

The Patak’s Chicken Tikka Masala (page 45) carries NTC information withan exclamation mark symbol. Many producers of ready meals,particularly Indian and Chinese recipe dishes have started to carry NTCinformation. Sometimes they use nuts in recipes on the same line.However, there is also a dilemma when using spices and other flavouringswhich are sourced from around the world, which are often dry, and whichshare production and packing facilities with hundreds of other foods,some of which may be allergens. This issue is the subject of continuingdialogue between the Anaphylaxis Campaign and the Spices andSeasonings Association.

The packet of Sea Salt (page 46) is an ‘ad hoc’ item from Holland andBarrett. Such products are sold in health food stores. Weighing out awide range of foods in close succession in a warehouse probably justifiesthe NTC labelling “Packed in an environment where nuts and sesameseeds are present.” However, this means that families wishing to buysimple ingredients in simple packaging, who care whether a product isorganic, or who are interested in its ethical background may wellencounter the risk of nut/sesame trace contamination.

The Haribo jelly sweets (page 47) do not carry NTC labelling, but are anexample of hard to read ingredients labelling. Once again, shiny paper,multilingual ingredients, upper case lettering and a tiny font will ensurethat the allergic customer needs to spend longer working out whetherthis product is ‘safe’. Another issue on similar products is to establishwhether they contain animal gelatine. This information is important forvegetarians and vegans.


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45

Patak’s Chicken Masala


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NTC labelling on sea salt from a health foodstore.


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Haribo Jelly sweets: These do not appear tohave NTC labelling but the ingredients arehard to read.


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Bertolli Pasta Sauce

‘May Contain’ Labelling – A Consumer’s Perspective

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Of the items missed by three out of ten sorters, one cereal packet hasNTC information conveyed in 19 tiny words, and the allergen box alsomentions wheat. All this information is only allocated 0.53% (3.92cm2) ofthe packaging surface. Although the labelling on this product adheres tocurrent industry guidelines the allergen information was missed by threeout of the ten shopping sorters. The allergen information was below theingredients panel and in dark text on a light background.

One new ingredient which has triggered NTC information on anadditional range of products is pesto. This is a paste which can be madefrom pine nuts and is used in pasta sauces. It may be the reason behindthe NTC labelling on the Bertolli jar.

Some allergic consumers report that they tend to become creatures ofhabit, staying with one retailer with whose labelling they have becomefamiliar. Shoppers who are new to reading allergen / NTC information, orwho only do so occasionally for an allergic guest may miss warningsaltogether. This study indicates that all of the retailers have examples ofadequate and inadequate NTC labelling. The items on which NTClabelling was most often missed were cereals (where the ingredients andallergen information cover a tiny percentage of the packaging area),packets of biscuits (with multi-coloured information on shiny paper), andbars of chocolate where the allergen information was often separatefrom the ingredients.

(Examples of the NTC wording from each retailer are listed at the end ofthis report.)

D: Review of recent AnaphylaxisCampaign NTC labelling enquiries

The Food Standards Agency also asked the Anaphylaxis Campaign toprovide additional information about current trends in allergen labelling,and to outline particular issues which have a significant impact on thelives of allergic consumers, reflect their concerns and merit furtherconsideration.

Health Food Stores

In line with the information above, the Anaphylaxis Campaign wouldadvise a nut allergic consumer to avoid the enormous range of simplypresented ingredients on sale in health food stores and on market stalls.The packing activity may involve frequent change-overs andopportunities for cross-contamination. A recent case of concern to theCampaign was the customer who found ten yogurt-coated peanuts in asmall packet of yogurt-coated raisins.

Small suppliers

The magazine “Inside-Story” has many subscribers with food intolerances,and advertises small independent suppliers of ‘health foods’, ‘alternative’products and manufacturers of products which are ‘free from’ certainingredients. Subscribers have recently been advised that these suppliers(many of which are very small-scale producers) may only be in a positionto eliminate one allergen (eg cows’ milk or wheat) from their products. Anew initiative is underway to encourage these suppliers to assess theirown risks and to inform their customers about trace contamination fromother allergens.

Farmers’ Markets

One Farmers’ Market was visited in November in St Albans. Home-cooked items were examined and discussed with the stallholders. TheWomen’s Institute stall had a wide range of bakery and other foodswrapped in cling film and plastic bags. There was a printed label on eachproduct which had been completed by hand in black/blue. Productswith nuts as ingredients had this written in red pen on the label. Thedialogue with the lady on the stall was less clear. She was vague aboutthe risk of trace contamination, and could not explain the Women’sInstitute (WI) nut labelling policy.

Some of the other stalls were held by small businesses preparing meats,making pies and other bakery items in farm kitchens. Three stallholderswere able to demonstrate a greater competence in managing allergen


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risk. They were far more aware of the issues of trace contamination, andit was very helpful to discuss the precise risk on an individual batch ofbread or pies.

One stallkeeper was selling decorative children’s biscuits which she hadmade. When asked whether any products had nuts in as ingredients, shereplied that they didn’t. However, about a third of the biscuits on salewere similar to macaroons. They actually contained almonds, but thestallholder hadn’t realised that almonds count as nuts.

Biscuits, cereals and confectionery

The products most commonly mentioned by Anaphylaxis Campaignmember families avoiding nuts and peanuts are cereals, biscuits andconfectionery. A detailed analysis of the study data indicated that 69%of the cereals, 58% of the biscuits and 56% of the confectionery itemsin Activity A had NTC labelling. This compared with an overall figure ofNTC labelling on 56% of all control basket items. None of these foodshad nuts or peanuts as ingredients.

In a letter to The Lancet, Accident and Emergency doctors in Swanseadescribed a research project in which they inspected 630 products(cereals, biscuits and confectionery) in four major supermarkets(8). Of allthe products, 15% had nuts as a declared ingredient, 25% appearedcompletely nut free and 60% carried some kind of nut contaminationwarning. (This correlates with our prevalence figure of 56%.) These figuresmight suggest that out of a sample of twenty UK cereals, biscuits andconfectionery, three would contain nuts deliberately, five would appearfree from nuts and twelve would have some nut contamination risk. Fromthe nut allergic consumer’s viewpoint, instead of a choice of seventeenproducts out of twenty (which did not have nuts as an ingredient), theycould choose from only five.

The Anaphylaxis Campaign has also investigated this problem, and worksclosely with key manufacturers to pass on information about theseproducts to its allergic members.

Cereals

In the UK, the cereal brand leader is Kellogg who can run its majorproduction lines (Corn Flakes, Rice Crispies) without using them for nutproducts. Shoppers often selected Kellogg’s Bran Flakes and Rice cerealsin the baskets for a nut allergic person. The majority of own brand cerealsfor a large number of retailers are made by a small number of othermanufacturers. They carry out relatively short production runs of a widerange of products, both with and without nuts, and have to implementfrequent change-overs between products. Such products are thereforemore likely to carry NTC information.


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Biscuits

The Anaphylaxis Campaign has been involved in a number of enquiriesabout biscuits and savoury snacks. Manufacturers have suggested that theUK market for traditional biscuits is fairly stable, and reported that theyare being encouraged to develop ‘added value’ or more up-marketproducts for new market sectors. In some cases, this involves the use ofmore expensive ingredients such as nuts. Their introduction in a minorityof products may then jeopardise the nut free biscuit range (custardcreams, digestives etc) if made on the same production line.

Confectionery

Some manufacturers have made particular efforts to source sweets forchildren without a NTC risk. Most nut allergic adults are resigned to thefact that they cannot eat the majority of chocolate products, and haveto examine labels on other sweets with care. The biggest problems aremulti-lingual labelling on small packaging, and colour combinationswhich are hard to find and hard to read.

Sesame trace contamination

During the course of the research period, the Campaign was contactedby a nut allergic member with an enquiry about NTC labelling on aChinese recipe sauce in a jar. Further investigation indicated that theproduct had no NTC risk, but contained toasted sesame. Not all nutallergic people are allergic to sesame, and the blanket use of NTClabelling for this purpose is not helpful to those who only need to avoidnuts and peanuts. This product also contained water chestnuts which areunrelated to chestnuts.


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E: Review of current allergen labellingon pre-packed foods

Nut Trace Contamination (NTC) information is printed on a wide range ofpre-packed foods. The wording, style, format and use of logos varyenormously from one retailer to another, and also from one producttype to another.

The decision-making process used to decide whether to use such NTClabelling also varies. Some retailers and manufacturers have been using itfor some time, and are committed to finding suppliers who aresegregating their production lines, working to eliminate nuts and peanutsfrom their ingredients, and keen to reduce the number of products whichneed NTC warnings. Others have now recognised the risks associatedwith nut and other allergen trace contamination, and have re-assessedtheir risks. This has led to NTC labels on some products for the first time.

The general rule adopted by many manufacturers is to avoid using majorserious allergens, and particularly nuts and peanuts unless their presenceis critical to the character of the product(9). This is in line with industryguidelines, and is also helpful in maintaining food safety ‘due diligence’. Inmany circumstances, it would now be considered unethical to develop anew product containing nuts or peanuts to be targeted at children, andmany manufacturers would consider carefully whether such a productfor adults might not have serious contamination implications for theintegrity of their other products.

One of the consequences of the increased awareness of potentially fatalfood allergies has been that manufacturers and retailers haveimplemented practices to assess and manage the risk of tracecontamination throughout their production and communicate it to theircustomers.

Major sources of industry guidance include the professional bodiesmentioned above, together with other papers published in medical,technical and professional journals. The Anaphylaxis Campaign itself isconsidered an authoritative source of guidance across the food industryand works closely with a wide range of UK manufacturers, retailers,caterers and consumers to improve the communication of allergen riskthe entire length of the food supply chain.

Whilst there is no legislation which covers allergen risk specifically, theFood Safety Act of 1990 covers all food sold to the public. Manufacturersand retailers who are aware of any potential food safety risk in theirproduct need to implement measures to prevent harm to theircustomers. This is known as ‘due diligence’ and means that foodbusinesses whose products may cause harm need to be able to


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demonstrate that they know about potential risks from their productsand can prove that they have measures and protocols in place to controlthem. Expectations of awareness and levels of risk management aregreater for larger food businesses.

Many allergic consumers find it impossible to accept that manufacturerscontinue to make nut free products in a nut contaminated environment.Some manufacturers claim that segregation is impractical and will be tooexpensive to implement. Others have managed such segregation. Bothmanufacturers and allergic consumers know that, in the circumstanceswhere trace contamination can kill, the only solution is full segregation,not just by time or through cleaning down the production lines butthrough running a separate production line in another area andimplementing measures to protect the allergen-free integrity of theproducts.

One frequently quoted problem for manufacturers is the ability to provethat the segregation measures in place are working. This depends on theavailability of practical and reliable testing methods for the allergenswhich they are managing. In the UK, there are recognised commerciallyavailable test kits (ELISA – Enzyme-Linked Immunosorbent Assays) for arange of allergens including peanut and hazelnut. It is hoped that one willbe available shortly for almond. The accuracy of such assays dependssignificantly on the characteristics of the food in which the allergen maybe present. Until reliable test kits with appropriate detection limits areavailable for all nuts widely used in UK recipes, manufacturers cannotprove conclusively that their segregation and clean-downs are working.

Some trusted ‘household name’ products are manufactured by foodbusinesses who have been aware of all these issues for at least 4-5 years,and who continue to make items without nuts as ingredients in a nutcontaminated environment. This contradicts the principle that using NTCand other allergen warning labels should only be a short term measurefollowing comprehensive and committed HACCP/risk assessment(9).Allergic consumers feel let down, particularly if they learn that a productwhich they have enjoyed and trusted may now carry a nut tracecontamination warning label.

One confectionery manufacturer (Kinnerton Gilchris) has pioneered theproduction of confectionery in a ‘nut free’ environment and uses a ‘nutfree’ logo to indicate this on its branded products. When these productsare sold under retailer brands, the ‘free from’ labelling is not used. Thissupports the principle that in the medium and long term, ‘free from’labelling should be unnecessary. It should be normal practice for foodsto be free from common allergens which are not ingredients. TheAnaphylaxis Campaign is keen to ensure that its allergic members canenjoy as many everyday food choices as possible, and should not berestricted to a minority of products carrying ‘free from’ labels.


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Some manufacturers and retailers have allergic customer databaseswhich they use to send out ‘free from lists’ which are regularly updated.Some allergic families find these very helpful, particularly for seasonalitems at Christmas and Easter. The databases also provide an immediatemailing list which can be used if required for a product alert or recall.Whilst it may be feasible to walk around a supermarket carrying theretailer’s own list, it is usually impractical to carry lists for everymanufacturer whose products people may wish to buy. In any case, thecontract between the retailer and the consumer is based on theinformation available at the time of purchase. The Anaphylaxis Campaignspends much time investigating discrepancies between information on‘free from’ lists and on packaging in-store and also between informationon inner and outer wrappers of multi-packs.

There have been a number of recent cases where manufacturers wereusing up old packaging with NTC information on products which weremade in strictly segregated ‘nut free’ conditions. It is exasperating for anallergic customer to have to be alert to such warnings, and then to betold elsewhere (eg by customer service personnel) that the product theyhave avoided is actually ‘safe’.


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ConclusionNut Trace Contamination is a problem affecting thousands of consumersand all those who share their food(1). Families with children who are nutallergic face daily problems finding, reading and believing nut tracecontamination information. Recent research in Canada indicated thatpeanut-allergic children suffer significantly more disruption in their dailyactivities than children with a rheumatological condition(10). Theadditional time required to shop, the extra cost and lack of choice ofmany everyday items all increase the disruption and stress on the wholefamily. Evidence from the Anaphylaxis Campaign’s workshops indicatesthat teenagers and young adults (who are most likely to suffer life-threatening allergic reactions) are least likely to take nut tracecontamination information seriously.

Not all allergic consumers recognise the diverse manufacturingconditions in which foods are made. Although some manufacturers ofpre-packed foods have implemented protocols using HACCP andrecognised guidelines(3) (5) to endorse the allergen-free status of theirproducts, there are many who have not. This is also the case for foodssold loose or foods sold in catering situations. Allergic consumers whounderstand these relative degrees of risk are obliged to buy pre-packedfoods from supermarkets and to avoid other food suppliers such as localbakeries, market stalls, craft food producers, health food stores andspecialist organic and other producers who supply through the post. It istherefore even more important that ingredient information onsupermarket pre-packed products is easy to find and easy to read. Inmany cases it is not.

Product labelling is one of a number of different communicationactivities in an ever-complex food supply chain. It is the main or solesource of information available at the point of sale, and for at least 1% ofthe UK population, it may have to communicate a potentially life-threatening risk. Consumer decisions about whether to trust a productdepend on how ingredients and allergen information are presented.Current labelling practices create difficulties for all customers, andparticularly the elderly. 1.7 million people in the UK are blind or partially-sighted(4) and many adults have poor literacy levels. In addition, manypre-packed products are used in smaller catering outlets where Englishmay not be the first language, where food allergy is poorly understoodand in situations where not all staff are literate.

Most major manufacturers and retailers in the UK use nut tracecontamination information to communicate a life-threatening risk whichmay affect at least one person in a hundred. It is poorly communicated,inconsistent, misunderstood, missed and ignored. This is potentiallydangerous.


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Recommendations1. Clear ingredient labelling is essential for all products, whether or not

they carry allergen information.

• The Recommendations of the Clear Labelling Task Force should beimplemented. This will help all consumers, and will improve theability of allergic consumers to carry out their own risk assessmentand make informed food choices

• The Food Standards Agency should consider additional ways toensure that all ingredients and allergen labelling follows industryguidelines and is ‘prominent and easily legible’.(3)

2. A high priority should be given to support manufacturers who seek to‘clean up’ by removing allergens from their production. This willinclude:

• The urgent development of reliable commercial assay test kits forother common allergens including different nuts

• Science-based research to develop cleaning protocols which willsupport manufacturers, retailers and caterers seeking to eliminateparticular allergens

• A recognised food production standard covering the entire foodsupply chain to objectively assess and endorse measures toeliminate any named allergen. In line with other quality standards,it should be independently audited and maintained.

3. This work should be linked into the current Food Standards Agencyinitiative examining information available for Foods sold loose andFoods sold in catering establishments, and all other consumer foodinformation initiatives.

4. The activities undertaken in this project should be repeated at regularintervals, (and possibly on a larger scale). The use of Nut TraceContamination and other allergen information should be monitoredby the Food Standards Agency.


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Annex 1

References

1. Tariq, Stevens, Matthews, Ridout, Twiselton, Hide, – Cohort study ofpeanut and tree nut sensitisation by the age of four years BMJ 1996 313:514-7 (Recent work is likely to suggest that more than one in 100children across the UK experience allergic symptoms to peanut.)

2. Class of 2001 – Grocer Magazine December 15th, 2001 41-98

3. Food and Drink – A Guide to its responsible management – GoodManufacturing Practice 4th Edition –Institute of Food Science andTechnology (UK) 1998 Dealing with allergens 124 – 128

4. Royal National Institute for the Blind – See it right 2001 Getting yourmessage across to customers with sight problems 7-9

5. This product may contain nuts – Voluntary labelling guidelines forfood allergens and gluten – May 2000 Institute of GroceryDistribution

6. Taylor S., and Hefle S., – Good Manufacturing Practices for allergenicfoods – Food Allergy and Intolerance Volume 2 Issue 1 2001 – 53 (andother volumes 2000 and 2001) – Leatherhead Food ResearchAssociation

7. Recommendations on Ideal Label Formats – Clear Labelling TaskForce 2002 Food Standards Agency

8. McCabe M., Lyons RA., Hodgson P., Griffiths G., and Jones R.,Correspondence The Lancet 12 May, 2001, 357, 1531 – 2

9. Gowland MH, Life-threatening food allergies: A survivor’s view – FoodAllergy and Intolerance Volume 2 Issue 1 2001 28 – 38 – LeatherheadFood Research Association

10. Primeau M-N., Kagan R., Joseph L., Lim H., Dufresne C., Duffy C., PrhcalD. and Clarke A. The psychological burden of peanut allergy asperceived by adults with peanut allergy and the parents of peanutallergic children Journal of Clinical and Experimental Allergy,Blackwell Science Ltd 2000, 30, 1135 – 1143


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Annex 2

Nut Trace Contamination Labelling Examples:

ASDA

• May contain traces of nuts and/or seeds

• May contain traces of nuts

Budgen

• May contain nut or nut traces

Co-op

• Allergy Advice: Produced in a factory handling nuts

Iceland

• This product has been made in a production area that uses nuts

• Made in a production area that uses nuts

• This product may contain traces of nuts

Marks and Spencer

• Logo: Not suitable for nut allergy sufferers

• Text: This product has been made in a factory which uses nutingredients

Safeway

• Not suitable for nut allergy sufferers

Sainsbury’s

• Due to the methods used in the manufacture of this product, it mayoccasionally contain nuts

Tesco

• Warning: This product may contain traces of nuts

Waitrose

• This product may contain traces of nuts


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Annex 3

Glossary of definitions

Anaphylaxis – A severe allergic reaction involving potentially life-threatening symptoms

Basket One – Goods selected in the control shopping trip

Basket Two – Goods selected suitable for nut allergic people

Brand label – A product sold under the manufacturer’s brand name

BRC – The British Retail Consortium

Control shopping – Using an unrestricted choice of the goods available

ELISA – Enzyme-Linked Immunosorbent Assay

EU – European Union

FSA – The Food Standards Agency

GMP – Good Manufacturing Practice

HACCP – Hazard Analysis Critical Control Points

IGD – Institute of Grocery Distribution

IFST – Institute of Food Science and Technology

MAFF – Ministry of Agriculture, Fisheries and Food

NTC – Nut Trace Contamination

Nut – For purposes of this report any reference to nut includes peanut(groundnut) as well as the tree nuts (hazelnuts, brazils, walnuts etc)

Own brand – A product sold under the retailer’s name

RNIB – Royal National Institute for the Blind

Trigger allergen – A food or other substance which causes allergicsymptoms


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‘may contain’ labelling – the consumer’s perspective

Documents